For HVAC Trainers: Section 608 Record Keeping

EPA supplied the ESCO Institute with over 400 revised questions submitted by the committee and other organizations for pilot testing.

Effective January 1, 2018, the new requirements for compliance with Section 608 of the Clean Air Act touches everyone in the refrigeration service chain, from trainers to technicians.

Randy Petit, Sr., has been serving as chairperson for the committee that is working to rewrite test questions for licensing exams. Now retired, he agreed to help ESCO Institute with the changeover to the new Section 608 exam.

Petit has been an important member of the ESCO Institute for many years, lastly as vice president of program development.

In a recent letter to subscribers to the ESCO Institute newsletter, Petit described some of the most important changes that trainers and test takers must keep in mind.

EPA

"Many questions have been going around about the new rules for Section 608 of the Clean Air Act. As a retired instructor given the opportunity to chair the committee to redo the exam questions, I think the changes made are an improvement to the test bank of questions," Petit wrote. "We tried to get rid of questions requiring dates, negative type questions and the ones with an “all of the above” answer."

EPA supplied the ESCO Institute with over 400 revised questions submitted by the committee and other organizations to do the pilot testing. Petit says the ESCO Institute is continuing to analyze the results to give feedback to EPA and to improve its new 28-page study guide.

According to Petit, the court filing by refrigerant manufacturers and some companies 'for' or 'against' the new rules may delay some of the projected dates for implementation of some rules. In addition, a few exam questions may need to be modified but not enough to affect what has been achieved so far.

"I find one of the big changes, besides the leak rates [minimums] for large systems, is the record keeping for disposal of appliances with 5 to 50 pounds of refrigerant. This one will affect all HVACR contractors," he wrote.

New records for the disposal of appliances containing between 5 and 50 pounds of refrigerant (scheduled to start on Jan.1, 2018) must be maintained by the technician/contractor.

Those records must include:

  • Company name, location of the appliance, date of recovery, and type of refrigerant recovered for each appliance
  • Amount of refrigerant (by type) recovered from all disposed appliances in each calendar month
  • Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the person to whom it was transferred, and the date.

Records must be maintained by the technician and not the owner or operator of the appliance.

Petit will provide additional updates in the days ahead.

Click below for a Section 608 brochure.

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